I. Information obtained when you visit Subscribers or our clients’ sites

Subscribers Collection and Use of Visitor Information

Subscribers Clients use the Analysis Service to obtain information regarding how Client Site Visitors to their Client Sites are interacting with such Client Sites (“Visitor Information”). This Analysis Service allows a Subscribers Client to evaluate and potentially modify its Client Site based on its findings regarding Client Site Visitors use and interaction with the Client Site. Please note that Subscribers itself uses the Subscribers Service to obtain insights into visitors’ activities on https://subscribers.com.

How Subscribers Collects Visitor Information

Subscribers Clients use customized and proprietary software code provided by Subscribers to collect and transmit Visitor Information to Subscribers’s servers. When a Client Site Visitor visits a Client Site that uses Subscribers’s Analysis Service, this code contacts Subscribers’s servers and enables Subscribers to collect and analyze the Client Site Visitor’s activity while visiting the Client’s Site. This information is then stored on web servers and databases utilized by Subscribers to perform analyses and produce reports for the Subscribers Client. The interactions that may be recorded or analyzed (“Recorded Interactions”) may include mouse scrolls and clicks by a Client Site Visitor; keystrokes entered by a Client Site Visitor; and/or pages viewed or visited by a Client Site Visitor, including the duration of such visits. Recorded Interactions may also include images of the Client Site that are recorded during the Client Site Visitor’s interactions with such Client Site, such as, by way of example, images of forms displayed or populated by the Client Site Visitor on the Client Site, or other multimedia content that may be posted by Client Site Visitors.

Subscribers may also collect certain information about a Client Visitor’s computer or mobile device that may be furnished by the Client Visitor’s browser or otherwise by the device (“Device Information”), such as:

Subscribers’s Analysis Service is not designed to knowingly collect or extract from Visitor Information (including any Recorded Interactions or Device Information) information that could be used to personally identify Client Site Visitors, such as a Client Site Visitor’s name, address or phone number (“Personally Identifiable Information”) when a Client Site Visitor visits a Client Site that uses the Subscribers Analysis Service. In particular, Subscribers does not attempt to identify, decipher, or associate Personally Identifying Information regarding a Client Site Visitor from any Recorded Interactions or Device Information. All information not constituting Personally Identifiable Information that Subscribers collects is pseudonymous information within the meaning of the General Data Protection Regulations.

Subscribers Does Not Collect Visitor Information Across Multiple Sites

Subscribers does not collect or aggregate information about visitor behavior on multiple, different websites, except insofar as multiple or updated versions of Our own Website may constitute multiple different websites.

Subscribers May Collect Information Contained in the “Referring URL” For The Last Website Visited

If a Client Visitor navigates to a Client Site from another website, Subscribers may receive certain information from the referring website (i.e., the last website the visitor visited before visiting the client’s website) as part of the Hypertext Transfer Protocol (“HTTP”) request. For example, if a Client Site Visitor navigates to a Client Site from a search engine, such as Google, Subscribers may receive information contained in the referring URL for the Google search query, such as the terms the Client Visitor was searching for before visiting the respective Client Site. Subscribers may use information contained in the referring URL to analyze and provide information to its Clients about the activities that led users to navigate to the applicable Client Site.

Subscribers’s Disclosure of Visitor Information

Except as disclosed in Section II below, Subscribers never sells or shares any Visitor Information with individuals or companies other than the specific Client from whose Client Site Subscribers collected the Visitor Information.

This Visitor Information is provided to Clients in the form of aggregated reports and/or statistics that identify the collective behavior of Client Visitors to the Client’s Site. Clients will also have access to Recorded Interactions through the Analysis Service.

Client Information

When individuals or companies register as Clients to use the Subscribers Analysis Service, register to use a trial version of the Subscribers Analysis Service, or request additional information about Subscribers, Subscribers may require Personally Identifiable Information, such as name, e-mail mailing address, phone number, financial information (e.g., credit card number, billing address), and/or website to be tracked, to process the registration or request (“Client Information”). When a client registers for the Subscribers Analysis Service, some of these pieces of information may be temporarily stored in encrypted format in a session cookie (but are not stored or linked to a permanent cookie). Subscribers may use this information to process and fulfill your request, register your account, check your qualifications for registration and/or to bill you for products and services. Subscribers may also use Personally Identifiable Information you submit to us to provide Subscribers’s products and services, personalize and tailor your experience on Subscribers, operate our business, understand how Clients are engaging with Subscribers, request additional information necessary to process or fulfill your order; determine if you are satisfied with the Subscribers Analysis Service; inform you that an upgrade is available; or to contact you with information about Subscribers, including information about new or existing products and services or special offers. For example, we may periodically send promotional materials or notifications related to our products and services to the email address associated with your account.

Policy Concerning Children Under Age of 13

Disclosure of Client Information to Third Parties

Subscribers may disclose Client Information (including Personally Identifiable Information) or Device Information collected from or concerning Clients or potential Clients to third parties in the circumstances described below and in Section II of this Privacy Policy. By registering for or accessing Subscribers’s products or services, you consent to such disclosure. This Policy does not apply to the policies or practices of any such third parties.

Right to be Forgotten

Users subject to the data privacy laws of the European Union and/or the United Kingdom may at any time issue a request to us that we remove, cease using, and/or permanently delete any information that you have submitted to us. Such valid requests will be honored promptly according to the applicable rules and regulations of the European Union and the United Kingdom. Any request to destroy some or all of the information you submit to us must be made in writing, to the designated contact information provided elsewhere on the Webpage. Information so destroyed or removed cannot be recovered; once destroyed, such information must be resubmitted by the user before we are able to verify, confirm, or disclose any such information in the future. Information so removed or deleted CANNOT be recovered under any circumstances and the failure of Subscribers to exercise any right or obligation to you necessitating any level of access to that information shall not constitute a material breach by Subscribers of any agreement so obligating Subscribers.

II. Provisions applicable to both visitor and client information

Disclosure of Visitor Information and Client Information to Service Providers and Law Enforcement/Legal Process

Visitor Information and/or Client Information (including Personally Identifiable Information) may be shared with certain third-party companies and individuals that help facilitate technical aspects of the Subscribers Service or perform functions related to the administration of Subscribers, such as third parties that provide storage facilities for certain Visitor Information and Client Information collected and analyzed by Subscribers. These third parties perform tasks on our behalf and are contractually obligated not to disclose or use Visitor Information or Client Information for any other purpose. However, Subscribers is not responsible in the event that Personally Identifiable Information is disclosed at a result of a breach or security lapse at any such third party, or for such third party’s non-compliance with the foregoing requirements.

Subscribers also reserves the right to disclose any Visitor Information or Client Information (including Personally Identifiable Information) to: (i) comply with any law, regulation, or legal request; (ii) enforce, apply, or investigate breaches of the Terms of Use or other agreements; (iii) respond to public requests; or (iv) protect the rights, property, user experience, or safety of Subscribers, our employees, our users, or others. We may also share Client Information and Visitor Information with our affiliates, subject to their compliance with our obligations under this Privacy Policy and the Terms of Use.

Security and Protection of Visitor Information and Client Information

Subscribers has implemented reasonable security mechanisms to protect Visitor Information and Client Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Examples of these security mechanisms include limited and password-protected access, firewalls, and SSL encryption to protect transmission of data. However, please keep in mind that no security system is impenetrable. It may be possible for third parties to intercept or access Visitor Information and Client Information. Subscribers cannot guarantee the security of such information and cannot be held responsible for and disclaims any liability for unauthorized access to Subscribers Client accounts.

Policy Concerning Children Under Age of 13

Subscribers does not knowingly or intentionally collect Personally Identifiable Information from children under 13. If we learn that we have Personally Identifiable Information of a child under age 13, we will remove it. If you believe we have Personally Identifiable Information about a child under the age of 13, please notify us at support@subscribers.com.

Change of Control

If Subscribers, or substantially all of its assets, is acquired by another company or successor entity, Visitor Information and/or Client Information will be one of the assets transferred or acquired by the purchaser or successor. You acknowledge that such transfers may occur, and that any purchaser of or successor to Subscribers or its assets may continue to collect, use and disclose your information as set forth in this policy.

Changes to Our Privacy Policy

Subscribers retains the discretion to amend or modify this policy from time to time. Use and disclosure of Information we obtain is subject to the later of: (1) the policy in effect at the time such Visitor Information or Client Information is collected or (2) any subsequent policy to which you agree or of which you have notice, if you elect to use Subscribers or a Subscribers Client Site (including the Subscribers Website) following such acceptance or notice. If we make material changes in the way we use or disclose Personally Identifiable Information, we will notify you through one or more of the following means: a direct communication to your Subscribers account, a communication to the e-mail address associated with your account, or a clear and prominent announcement on the Subscribers Website. Your continued access to or use of Subscribers or websites that use Subscribers following notice of material changes to this Privacy Policy shall constitute consent to any amendments and/or modifications.

For More Information / Your Information Rights

Subscribers welcomes any questions or comments about this Privacy Policy or our privacy practices, including regarding any disclosure of third party information for direct marketing purposes. Any such comments or questions should be submitted via e-mail to: support@subscribers.com.

Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once per calendar year certain disclosures about the personal information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of personal information, and the names and addresses of those businesses with which we shared personal information, for the immediately prior calendar year (e.g. requests made in 2016 will receive information regarding 2015 sharing activities). To make such a request, please send an email to support@subscribers.com with a subject line of “Request for California Privacy Information.” Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Transfer of Data Abroad; International Users

If you are visiting the Our Website or a Client Site from a country other than the United States of America the various communications will necessarily result in the transfer of information across international boundaries. By visiting the Our Website or the Client Site, as applicable, you consent to the processing and transfer of your data as set out in this Privacy Policy. By using the Our Website or the Client Site, as applicable, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States.

Effective Date of this Privacy Policy

This document is in effect as of October 18th, 2018.